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January 12, 2021

ICF/IID Meeting with ODH. Today, OHCA met with the Department of Health (ODH) and the Department of Developmental Disabilities (DODD) to discuss ICF-related regulatory issues. Two items of note from the meeting are:

  1. ICFs may need to revisit their tuberculosis (TB) testing policies to comport with previously shared Centers for Disease Control and Prevention (CDC) guidelines on COVID-19 vaccination. The guidelines recommend TB testing before vaccination, but if a provider has a new hire who already received the first dose of the vaccine, they would need to wait four weeks following the last vaccine dose to administer the TB test. ODH pointed out that providers still should do TB symptom screening, but it is acceptable to wait to do the TB testing so the new hire can get vaccinated. Again, for survey purposes, you should review your TB testing policy to ensure it allows a delay in TB testing under those circumstances.

  2. ODH currently is developing a plan to restart annual ICF certification surveys. ODH's Rebecca Sandholdt said this will be a huge undertaking and will take some time to finalize, but ODH intends to begin with the facilities that are most overdue. Ms. Sandholdt expressed concern that ODH will not be able to complete the certification/licensure surveys for all ICFs with licenses set to expire on June 30, 2021, by that date (all ICF licenses with December 31, 2020, expiration dates were extended to June 30). DODD will work with ODH to determine a path forward for ICFs that ODH is not able to survey before the license extension expires.

Ohio Appendix K Extension. Ohio submitted a request to the Centers for Medicare and Medicaid Services (CMS) to extend the current Appendix K, which is set to expire on January 26, 2021. However, in conversations with DODD, we learned that CMS requested that Ohio submit only the extension request for approval at this time, not any new items, which would include both the lump-sum provider payment for DD waiver services and additional SELF waiver slots. Once the extension is approved, Ohio can submit another Appendix K request for the new items. Given that other states also will be submitting extension requests at the same time, we unfortunately anticipate there may be a delay in CMS’s approval of the lump-sum payment. DODD is still hopeful that CMS will approve the Appendix K requests quickly. OHCA will continue to update members as we learn more about the timeline for disbursement of the waiver payments.

Assisted Living and SNF Testing Schedules; AL Result Reporting. The Department of Aging released the next testing schedule for both SNFs and assisted living communities. The schedule runs through February 12 for assisted living and February 10 for SNFs. In addition, the new iteration of the now-weekly assisted living test result reporting tool is open. The reporting, which is for period December 28 to January 3, is due tomorrow.

Point-of-Care Reporting Through ODH. Now that the Department of Health and Human Services has lifted the mandate for SNFs to report point-of-care (POC) antigen test results to the National Healthcare Safety Network (NHSN), we would like to remind members that ODH’s COVID-19 Reporting webpage contains all the information facilities need to establish a direct connection with ODH to begin line-level reporting. While OHCA will continue to help members with issues obtaining Secure Access Management System (SAMS) Level 3 access, we encourage members who have not yet succeeded to consider direct reporting to ODH, particularly because resolution of SAMS Level 3 issues is slow. Under the tab on the ODH page, “Establishing a Secure Connection with ODH and File Validation,” ODH prefers providers use the option to establish an account within the Authenticated Web Portal to upload their line-level data. ODH has a team of 13 staff members working to on-board Clinical Laboratory Improvement Amendments (CLIA)-waived labs as quickly as possible. Additional reporting resources, including training videos, also are available on the site.     

SBA Reopens Applications for PPP Loans. The US Small Business Administration (SBA) announced on January 8, 2021, that the Paycheck Protection Program (PPP) would reopen on January 11 for new and existing PPP borrowers. PPP loans are to cover additional expenses, including operations expenditures, property damage costs, supplier costs, and worker protection expenditures. Existing PPP borrowers can apply to increase their First Draw PPP Loan amount if they meet additional requirements, such as having fewer than 300 employees. The new guidance released includes:

Monoclonal Antibody Education Session Tomorrow. Now that long-term services and supports providers have access to monoclonal antibodies (mAbs), you may have questions about using this treatment and how it may relate to vaccine administration. At 2:00 p.m. tomorrow, Wednesday, January 13, the University of New Mexico’s Project ECHO will host a free mini-series program addressing common questions and concerns about mAb treatments. The program will include:

  • An overview and question answer session on how mAbs are used in treatment of COVID-19.
  • An opportunity to ask questions of a panel of experts, including representatives from CDC, AMDA - The Society for Post-Acute and Long-Term Care Medicine, and providers currently utilizing the treatment.

For registration and connection information, click here.

Monoclonal Antibody Administration: Ohio Rate Update. The first week of January, CMS released the locality-adjusted rate file for the mAb infusion treatment. Per the enforcement discretion relating to certain pharmacy billing, which states that COVID-19 treatments and vaccinations are excluded from consolidated billing if delivered by a Medicare immunizer such as a SNF or home health agency, Medicare immunizers that administer mAbs can bill under Medicare Part B for reimbursement. For Ohio, the locality-adjusted rate for calendar year 2021 is set at $286.84. For a full list of billing codes and instructions, please see the CMS website.

Aetna Extends SNF PA Waive through February 15, 2021. Aetna extended the initial pre-certification/prior authorization (PA) waiver for SNF admissions, which originally was set to expire on January 11, 2021, through February 15, 2021, for all commercial and Medicare Advantage beneficiaries. SNFs must notify Aetna of admissions within 48 hours and must send medical records for concurrent review within 3 days of admission. Medical records can be uploaded through Availity or can be sent by fax. Aetna requires both hospitalization history and SNF progress notes since admission. This waiver does NOT apply to SNF-to-SNF transfers or to level of care changes within a SNF. We updated our OHCA SNF Prior Authorization Waiver Grid to reflect these changes.

As a reminder, the SNF PA waiver for Aetna Better Health of Ohio is in place through January 31, 2021, and also requires notification within 48 hours of admission. We will continue to check back for updates as the deadline approaches.

State Announces Phase 1B Vaccination Schedule. At his press conference today, Governor Mike DeWine announced the initial schedule for Phase 1B of the state's COVID-19 vaccination plan. ODH will inform local health departments tonight about the vaccine providers ODH selected and how much vaccine they will receive from next week's federal allocation. The local distribution plans will be communicated to the public starting tomorrow. On Thursday, ODH will open a tool on its COVID-19 website for members of the public to find out where and how they can get vaccinated.

The state listed the vaccine roll-out schedule, which is subject to change, as follows:

Week of January 18: People 80 and older. 

Week of January 25: People 75 and older and those with severe congenital, developmental, or early-onset medical disorders.

Week of February 1: People 70 and older. 

Week of February 8: People 65 and older. 

According to the Governor's Office press release, providers will receive vaccines on Monday, Tuesday, and Wednesday of each week and must begin vaccinating Phase 1B individuals the next day. All vaccines must be administered within seven days.